1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. SERMATECH TECHNICAL SERVICES, A PENNSLYVANIA CORPORATION LONE STAR DEVELOPMENT AND CONSTRUCTION, INC., A TEXAS CORPORATION 25 SOUTH BELT INDUSTRIAL DRIVE HOUSTON, HARRIS COUNTY, TEXAS 77053 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENTS CONDUCTED THE RELEVANT ACT- IVITIES AND OPERATE THE FACILITY WITHOUT NPDES PERMIT 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308(A) AND 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENT TO: A) WITHIN 30 DAYS, OBTAIN NPDES PERMIT COVERAGE, SUBMITTING A COPY OF THE APPLICA- TION, CONFIRMATION OF COVERAGE AND THE PERMIT NUMBER TO EPA; B) WITHIN 30 DAYS, TAKE CORRECTIVE ACTION TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLIANCE; C) WITH IN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECI- FIC ACTIONS TAKEN AND EXPLAIN HOW THE ACTIONS WILL PRE- VENT RECURRENCE; D) IF NOT POSSIBLE TO CORRECT THE VIOLA- TIONS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME; AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.